Articles and Blogs

Health care continues to drive private equity (“PE”) activity, creating opportunities for investors and traditional health care providers. Transactions in the health care space are especially complicated, layering health care regulatory and reimbursement considerations on top of a complex securities, antitrust, privacy and security framework. Hall Render’s PE team of attorneys and advisors leverage... READ MORE

On December 2, 2024, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) issued a proposed rule (“Proposed Rule”) that amended the regulations relating to exclusion authorities under the authority of OIG. The Proposed Rule would codify changes made by the Medicaid Services Investment and Accountability Act... READ MORE

On December 5, 2024, an Alabama federal judge granted preliminary approval for the Blue Cross Blue Shield (“BCBS”) settlement. As part of the agreement, BCBS will pay $2.8 billion to a Settlement Fund and implement transparency and accountability measures to address alleged anticompetitive behavior. For a detailed discussion of the BCBS settlement, please see... READ MORE

The Food and Drug Administration’s (“FDA”) Office of Prescription Drug Promotion (“OPDP”) has issued its fifth Untitled Letter of the year, matching last year’s total number of enforcement letters. As a reminder, OPDP issued four Untitled Letters and one Warning Letter in 2023. So far this year, FDA has not issued any Warning Letters.... READ MORE

NATIONAL 5 multimillion-dollar Stark law penalties in 2024 5 Deals That Defined Hospital M&A in 2024 50 Joint Commission moves in 2024 Bristol Myers Squibb latest drug company to sue HHS over 340B rebate model CMS finalizes new kidney transplant model: 10 things to know CMS updates immediate jeopardy guidance: 4 key changes CMS... READ MORE

A recent report found that financial stability and margins improved for nearly half of rural hospitals after a merger, acquisition or affiliation with a larger system. More than a quarter of rural hospitals currently have negative operating margins. As inpatient stays shorten, providers are shifting capital investments from acute-care hospital facilities to outpatient construction... READ MORE

On December 3, 2024, the United States District Court for the Eastern District of Texas (“the Court”) issued a nationwide preliminary injunction that prevents the federal government from enforcing the Corporate Transparency Act (“CTA”). As a result—and for the time being—millions of entities across the United States are no longer required to submit beneficial... READ MORE

On October 10, 2024, the Federal Trade Commission (“FTC”) announced their unanimous vote to finalize changes to the premerger notification form and associated instructions, as well as the premerger notification rules implementing the Hart-Scott-Rodino (“HSR”) Act. The HSR Antitrust Improvements Act of 1976, as amended, requires all persons contemplating certain mergers or acquisitions that... READ MORE

Health care continues to drive private equity (“PE”) activity, creating opportunities for investors and traditional health care providers. Transactions in the health care space are especially complicated, layering health care regulatory and reimbursement considerations on top of a complex securities, antitrust, privacy and security framework. Hall Render’s PE team of attorneys and advisors leverage... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) provided additional details and information related to CMS provider enrollment site visits. On November 4, 2024, CMS issued a Quality and Safety Special Alert memo (“QSSAM”), “Clarification of CMS’ Provider Enrollment Visits (all providers and suppliers) and Specific Disclosure Requirements for SNFs and NFs.” CMS provides... READ MORE